Will America go from hunter to hunted in cross-border tax evasion?

Many countries are on the offensive in the search for secretly stashed cash

launched brutal assaults over the past decade on countries, such as Switzerland and Liechtenstein, where banks have helped American citizens hide money and thereby evade tax. Forced to clean up, these erstwhile havens have seen much tainted capital flow elsewhere—not least to America itself. Now it is the former aggressor’s turn to be on the defensive.

Until now the biggest user of such summonses in tax cases has been America, which, for instance, used the procedure in 2008 to prise open Swiss bank secrecy. That resulted inhanding over the names of around 4,500 account-holders. In April the tables were turned when a request from Finland prompted America’s Internal Revenue Service to petition a federal court in North Carolina for leave to serve John Doe summonses on three banks in America.

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